Title: Letter to Mr. Quinn Re: Revised Public Workshop Draft of the 1995 Florida Land Plan: The State Land Development Plan; Notice of Additional Substantive Revisions
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 Material Information
Title: Letter to Mr. Quinn Re: Revised Public Workshop Draft of the 1995 Florida Land Plan: The State Land Development Plan; Notice of Additional Substantive Revisions
Physical Description: Book
Language: English
 Subjects
Spatial Coverage: North America -- United States of America -- Florida
 Notes
Abstract: Jake Varn Collection - Letter to Mr. Quinn Re: Revised Public Workshop Draft of the 1995 Florida Land Plan: The State Land Development Plan; Notice of Additional Substantive Revisions (JDV Box 39)
General Note: Box 29, Folder 11 ( 1995 Florida Land Plan ), Item 3
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
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Bibliographic ID: WL00004960
Volume ID: VID00001
Source Institution: Levin College of Law, University of Florida
Holding Location: Levin College of Law, University of Florida
Rights Management: All rights reserved by the source institution and holding location.

Full Text

A P


Steel Hector & Davis
Taanasse. FRonda
Robert M. Rhodes
(904) 222-2300

Jake Varn RECEIVE
Working Copy AUG 2 1995
HAND DELIVERY Working Copy a z s
Carlton Fialds Tallahassee
*-- "*',rn


August 25, 1995




Mr. Jim Quinn
Chief, Bureau of State Planning
Department of Community Affairs
2740 Centerview Drive
Tallahassee, Florida 32399-2100

RE: Revised Public Workshop Draft of the 1995 Florida Land Plan:
The State Land Development Plan

Dear Jim:

On behalf of the Florida Association of Realtors, we
appreciate the opportunity to review the above referenced draft and
submit these comments.

We share the concern of many others that given the imminent
revision of the State Comprehensive Plan (SCP), which guides the
State Land Development Plan, this draft should be deferred.

In addition to substantive revisions that will be proposed to
the SCP, the Legislature is expected to review and possibly modify
the role of the State Land Development Plan and the process by
which it is prepared and adopted. These are sufficient reasons to
defer action on this draft. That said, we share with you our
concern that numerous proposals would establish significant state
policy that merits legislative review before it is embedded in any
state agency plan. Examples include:






Miami OIe Wes Palm Beach Ofice Tdalmlah Office
41 Floor 1900 Phfips Poir Wet Suite 601
200 Soulh Bicayne Bouleard m7 Soul Flager Drive 215 Soah Monroe
Mwni. FL 33131.2396 We Palm Beach. FL 33401-6196 Talahelse. FL 32301-1804
(305) 7s.7000 (407)650-7200 (904) 2222300
Fax (o ) 577.7001 Fac (407) 855.1500 Fx (904) 222-8410







Steel Hector & Davis


Mr. Jim Quinn
August 25, 1995
Page 2



REGULATORY POLICIES
Land Use

Requiring that densities be increased within urbanized areas
before local governments can expand the perimeter of an
urbanized area. Goal 1, Objective 1.
Promotion of land development patterns that result in compact,
self-contained, "sustainable" communities. Goal 1.

Directing local government to avoid designating or permitting
development of "substantial areas" as low intensity, low
density, or single use development. Goal 1, Policy 10.

Directing local governments to avoid designating or permitting
development that disproportionately increases the cost in
time, money, and energy in providing infrastructure and public
services when compared to promote compact growth patterns.
Goal 1, Policy 15.

The entire discussion of property rights is stale and should
be updated to reflect the economic consequences to property owners
that flow from stringent regulations. A highlight subject should be
the recently enacted property rights legislation, and particularly
provisions that will compensate regulated landowners who must bear
an "inordinate burden" that in fairness should be borne by the
community. Goal 3.

Natural Resources

Requiring that the state assure the "sustainable use" of
ground and surface water resources. Goal 1, Objective 3.

Promoting a program to protect diverse habitat and
biodiversity. Goal 3, Policy 9.

Directing government to avoid fragmentation of "large tracts"
of natural resources and facilities of state significance.
Goal 3, Policy 12.






Steel Hector & Davis

Mr. Jim Quinn
August 25, 1995
Page 3

Establishing a policy of "no net loss" of endangered and
threatened species habitat. Goal 3, Objective 4.

Affordable Housing

Requiring that affordable housing efforts emphasize provision
of units affordable to households with incomes below 50% of
the state's median household income.

ADVOCACY POLICIES

We request that all "advocacy policies" be deleted.
Experience indicates that plan users will not differentiate between
goals, objectives, and policies that will be used in a regulatory
manner and advocacy policies that are provided only as "a useful
reference". Numerous advocacy policies would establish far
reaching state policy that clearly should be reviewed by the
Legislature. In sum, these policies should only be "advocated" as
Department proposals to amend and supplement the SCP.

Here are some examples:

Land Use

Establishment of urban development boundaries. Goal 1,
Advocacy Policy 2.

Natural Resources

Establishing a "no net loss of wetlands" policy by "utilizing
the concept and principles of ecosystem management." Goal 1,
Objective 4, Advocacy Policy 1.

Establishing incentives to encourage the retrofitting of
current stormwater treatment systems. Goal 1, Objective 5,
Advocacy Policy 1.

Implementation of a statewide wildlife conservation system and
the Florida Greenway System. Goal 3, Objective 1, Advocacy
Policy 1.


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Steel Hector & Davis


Mr. Jim Quinn
August 25, 1995
Page 4

Implementation of the ecosystem management initiative. Goal
3, Objective 1, Advocacy Policy 2.

Requiring all state actions be consistent with plans and
strategies identified through the SWIM program, resource
planning and management committees, and areas of critical
state concern process. Goal 3, Objective 1, Advocacy Policy
4.

RESOURCES AND FACILITIES
OF STATEWIDE SIGNIFICANCE

Resources and facilities should not be deemed of state
significance solely because they may require "the participation or
involvement of the federal government, the state government, or two
or more regional governmental entities to ensure proper and
efficient management" (Appendix A, Designation Criteria 2). This
designation criterion exalts process over substance. Resources and
facilities should be designated of state significance because of
their character or function, and not because various governmental
entities may show some interest.

If you proceed with action to adopt this plan, we'd like an
opportunity to discuss with you the appropriateness of listing
several of the resources and facilities noted in Appendix A.

Thank you for considering our comments.

Sincerely,



Robert M. Rhodes

/m12072

c: Gene Adams
Jim Murley
Charles Pattison
Dan Stengle
Vicki Weber




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